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Andrew Luker Comment On Regulatory Notice 22-08

Andrew Luker
N/A

To Whom it May Concern,

I have been an active investor for several years, and invest in 3x Leveraged ETFs (both long and inverse), and they have been a very important part of my strategy, although I am not a 'high net worth' investor. Without these, I'd have to have 3 times the capital to get the exposure I need in order to succeed.

I know these products are important to me and others who have them as an active part of their strategy. I use them as a partial part of my overall portfolio, and they act as an important hedge or supplement to my other non-leveraged investments.

Please DO NOT restrict these ETFs to investors, as I believe they are an important way to succeed in the complex markets today. Although they are not for everyone, for active/semi-active traders they can be critical for success.

Thank you for your consideration.